Today HMRC released updated Guidance Notes on implementing FATCA in the UK. These guidance notes supersede the version released on 14 August 2013 and reflect the contributions received from UK businesses and advisers prior to the updated US FATCA Regulations issued by the IRS and US Treasury on 20 February 2014.
HMRC states that further amendments and additions to this guidance will be required as a result of the changes to the US Regulations, however, significant changes will be published as stand alone updates. This guidance will be consolidated to include these updates along with all other necessary changes at 6 monthly intervals. As such the next updated guidance will be published in August 2014.
The updated Guidance Notes provide clarity on a number of points that have raised concerns with the industry, such as the treatment of holding companies, sponsored entities, trusts as well as some of the due diligence procedures. We are analysing the guidance and will provide further comments next week.
View the updated Guidance Notes.
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